E.D. Pennsylvania cuts special education fee award 20%, including for clerical work

What happened

The plaintiffs in an IDEA case against Interboro School District requested $33,948.50 in fees and costs. Judge Juan R. Sánchez awarded $27,158.80, a reduction of $6,789.70 or 20%. The court applied a further 20% cut to the requested amount after weighing the plaintiffs' partial success, their voluntary 25-hour reduction, the significance of an independent FBA obtained, and billing concerns raised by the district, including block-billed entries, time on clerical tasks, pre-complaint IEP work, and entries that appeared excessive.

What the court said

The District also identifies several billing concerns with sufficient specificity, including block-billed entries, time spent on clerical tasks, pre-complaint IEP-related work that may not be compensable under § 1415(i)(3)(D)(ii), and time entries that appear excessive for the tasks described.

The court also reduced the award for: limited success, excessive hours.

Why it matters

The ruling shows that a fee applicant's time records can draw a percentage cut even alongside a voluntary hours reduction, where entries mix clerical tasks, block billing, and work of uncertain compensability. Courts may apply one aggregate reduction rather than itemizing each concern.

How to keep this out of your fee petition

• Leave purely clerical work off the fee petition.
• Describe paralegal tasks so the substantive work is clear.
• Split mixed entries into their substantive and clerical parts.

Cite this ruling

See hourly rates the E.D. Pennsylvania approves and attorney fee motions in Pennsylvania federal courts.

Figures and quotes are taken from the opinion and checked against its text. Spot an error? Email team@legaltime.ai with the case name and we will correct it. Summaries of public court opinions. Not legal advice.